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    <description>The Tribunal deemed the reopening of assessment after four years invalid as it lacked fresh tangible material and failed to disclose any new facts, setting aside the assessment. The loss on sale of shares was classified as a business loss, not a capital loss, as it was clearly visible in the profit and loss account and had been disclosed in the original return. The reopening was found to be based on a valid consideration of the nature of the loss, rather than a change of opinion, as the Assessing Officer had the opportunity to review the relevant information during the original assessment.</description>
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